ASA sponsored a webinar October 28th on aircraft parts documentation expectations after Brexit. One of the questions raised was whether the EASA certificates that will be issued to certain businesses (as third-country approval holders) will be the same as the comparable UK CAA certificates. The short answer is that the certificate numbers will be similar, but the EASA certificates will have a different prefix in order to make them distinguishable.
As part of the webinar, we discussed the EASA offer to issue third-country certificates [like repair station certificates and production organization authorizations] to UK-based businesses. The process is that the UK-based company applies to EASA for third-country approval;
- EASA assesses the company’s fitness to hold an EASA approval;
- The fitness assessment is carried out by EASA’s technical agent in the UK (UK CAA);
- EASA maintains a list of UK-based companies that will get EASA third-country approvals;
- Immediately after Brexit, EASA will email copies of the new approvals to the UK-based companies;
- The EASA approvals will be equivalent to any other EASA-third-country approvals;
- The UK-based companies will continue to hold their UK CAA approvals, as well.
The two most important EASA approvals, for most of ASA’s members, will Maintenance Organization Approvals (MOAs) and Production Organization Approvals (POAs). ASA members may wish to know which of their UK-based business partners have opted to apply for EASA third-country approvals. You can find the lists here:
- List of third-country production organization approvals that will be issued in the event of a hard Brexit
- List of third-country EASA 145 approvals that will be issued in the event of a hard Brexit
Both of these lists are tentative, in that they describe applicants from the UK, who will not be issued their credentials until and unless the UK leaves the EU.
It appears that the current UK CAA MOA certificates numbers are in the form “UK.145.nnnnn” where “nnnnn” is a five-digit number. EASA anticipates issuing MOA certificates in the format “EASA.UK.145.nnnnn” where “nnnnn” is the same five digit number that was issued by the UK CAA. For example, Patriot Aviation Engineering’s UK CAA certificate number is UK.145.00002. They have applied for third-country certification from EASA. Upon Brexit, EASA intends to issue to Patriot an EASA MOA certificate number EASA.UK.145.00002.
A similar pattern emerges for POAs. The current UK CAA POA certificates numbers are in the form “UK.21G.nnnn” where “nnnn” is a four-digit number. EASA anticipates issuing POA certificates in the format “EASA.UK.21G.nnnn” where “nnnn” is the same four-digit number that was issued by the UK CAA. For example, Dunlop Aircraft Tyres’ UK CAA certificate number is UK.21G.2008. They have applied for third-country certification from EASA. Upon Brexit, EASA intends to issue to Dunlop an EASA POA certificate number EASA.UK.21G.2008.
As we discussed in the webinar, which authority is responsible for the documentation can have a dramatic effect on which authorities are able to accept that paperwork. Look carefully at the documentation you receive, so you know whether the documentation is signed-off under the UK CAA approval number or under the EASA approval number.